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Petitioner received $72,821, $54,086.38, and $57,575.69 in
wages from Contract Services Co. during 1996, 1997, and 1998,
respectively. Federal income tax of $3,071.14 was withheld from
petitioner’s wages from Contract Services Co. in 1998; no Federal
income taxes were withheld in 1996 and 1997. Petitioner received
$9,410 and $17,740 in nonemployee compensation from Acorn Product
Development, Inc., during 1997 and 1998, respectively. On
December 9, 1998, petitioner sold a single family residence
located at 2716 Morrene Drive, Placerville, 95667 for $112,500.
Petitioner was the owner of this property immediately prior to
its sale.
Petitioner did not file Federal income tax returns for 1996,
1997, or 1998. Respondent issued a notice of deficiency to
petitioner, and petitioner filed a petition with this Court.
OPINION
A. Income Tax Deficiencies
Section 61(a)1 includes within the definition of gross
income, “all income from whatever source derived” including
compensation for services and gains derived from dealings in
property. See United States v. Connor, 898 F.2d 942, 943 (3d
1Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the tax years in issue,
and all Rule references are to the Tax Court Rules of Practice
and Procedure.
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